Public Comment to EPA on National Ambient Air Quality Standards for Ozone

This rulemaking is potentially one of the most consequential regulations in recent years, with cost and benefit estimates in the billions of dollars for any of the three standard levels under consideration. However, this comment focuses primarily upon the proposal’s intrinsic feasibility under some of the agency’s own assertions and assumptions. The two areas I address in particular are: 1) unknown control technologies, and 2) the transportation of ozone.

Sue and Settle Reform, SCRUB Act Could Save $48 Billion, 1.5 Billion Hours

The U.S. House is expected to vote soon on two pieces of legislation to streamline and provide increased oversight to the regulatory system. The Sunshine for Regulatory Decrees and Settlements Act would curb practice known as “sue and settle,” where special interests are given a say in significant federal regulations and the SCRUB Act (Searching for and Cutting Regulations that are Unnecessarily Burdensome), which would establish an independent commission with the goal of reducing cumulative regulatory burdens by at least 15 percent. According to research from the American Action Forum (AAF), savings from these bills could total $48 billion annually and save 1.5 billion paperwork burden hours.

The “RAPID” Act; H.R. 712, The “Sunshine for Regulatory Decrees and Settlements Act of 2015;” and The “SCRUB Act”

It is because regulatory reform has failed so often in the past that we continue to talk about its place in the future. Whether it’s the failure of agencies to comply with the Paperwork Reduction Act, the Congressional Review Act, or the current executive orders, it’s clear there are opportunities for meaningful reform that address cumulative burdens and the regulatory process. The proposed legislation could generate substantial regulatory savings. 

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